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HMRC internal manual

Double Taxation Relief Manual

Double Taxation Relief Manual: Guidance by country: Ireland: Dividends

A United Kingdom insurance company which carries on any insurance business which is charged to tax under Case I of Schedule D is entitled to relief under ICTA88/S802 (see the General Insurance Manual and Life Assurance Manual) for any Irish Corporation Tax (and United Kingdom Corporation Tax and third country taxes) underlying dividends received from Irish companies which are referable to that business, if that business, or any part of it, is carried on through a branch or agency in Ireland.